‘Adults Only’: what to do if your online service allows pornography

Online safety Online pornography Illegal and harmful content Information for industry
Published: 16 July 2024
Last updated: 13 January 2026

If you have an online service that allows pornographic content, this page will help you to understand your duties under the Online Safety Act.

It explains what you need to know and do to ensure you follow the rules. You might provide an adult service such as a tube, cam or fan site.

Our Guidance on Content Harmful to Children (PDF, 806 KB) contains detail on what Ofcom considers to be pornographic content, including additional content and examples.

Pornographic content means content of such a nature that it is reasonable to assume that it was produced solely or principally for the purpose of sexual arousal.

Content depicting full frontal nudity or depicting genitals, breasts or buttocks to elicit sexual arousal

  • Any content focusing on the breasts (with or without exposed nipple, depending on the context), genitals or buttocks or depicting full frontal nudity.
  • Videos showing an individual with exposed or partially exposed genitals, breasts or buttocks where they are using language associated with sexual activity or pornography (for example, ‘milf’ or ‘horny’), or strongly suggesting sexual activity (for example, moaning or simulating masturbation or oral sex).
  • An autonomous sensory meridian response (ASMR) video where sexually suggestive sounds are combined with full or partial nudity.

Explicit depictions of sexual activity

  • Depictions of sexual acts such as masturbation, oral sex, penetration or ejaculation, including where these acts are performed with or on a sex toy.

Fetish material

  • Depictions of an individual with their breasts, buttocks or genitals exposed depicting bondage, discipline, sadism and/or masochism (BDSM) or any other fetish depictions.
  • Depictions of an individual being whipped or restrained containing language associated with sexual activity or pornography (for example, ‘milf’ or ‘horny’), or other strong suggestions of sexual activity (for example, moaning or simulating sexual activity).

Explicit audio material

  • Audio material includes graphic descriptions of sexual activity and/or sexual soundscapes, (for example, moaning combined with rhythmic bodily contact sounds) that are sexual in nature and are intended solely or principally for sexual arousal.

Text-based content of a sexual nature: this includes text-based content of a sexual nature accompanied by GIFs (that are not sexual in nature), emojis or symbols

  • Written erotica or fan fiction.
  • A non-sexualised emoji or GIF alongside text-based content of a sexual nature.
  • Audiobook material/erotica in which character development, narrative structure and/or unabridged adaptation of the written word means that the sole or principal purpose of the work is not for sexual arousal.

Glamour content whose primary purpose falls short of sexual arousal, but may have suggestive intentions

  • A video of someone playing a video game in swimwear.
  • Sexualised or suggestive content of a kind that might be expected to feature in an advertisement.

Content depicting partial or full nudity in a non-sexual context

  • Content depicting breastfeeding.
  • Content depicting nudity for a comedic or satirical purpose.
  • Journalistic content including images of non-sexual nudity.

Educational material which includes imagery of, or discussion about, anatomy, nudity or sexual activity

  • Anatomical diagrams.
  • Content intended for the sex education of children.
  • Depictions of penetration in a medical context, e.g., a demonstration of an intimate examination.
  • Academic material, such as historical, sociological or anthropological content, presented and appropriately contextualised as one might expect to find in an encyclopaedia or academic journal.

Dramatic or comedic content where nudity or sexual activity is secondary to the dramatic or comedic purpose of the content

  • Depictions of nudity or sexual activity that are not shown in graphic detail and where a comedic or dramatic purpose is clear. This may include clipped footage of a sex scene from film or television, where the sexual activity is not shown in graphic detail and the dramatic purpose is evident and retained in the clip, such as through a combination of factors such as the inclusion of a storyline, character development and/or narrative device.

Artwork featuring nudity or sexual activity where the primary purpose is artistic

  • Content depicting sexually suggestive dancing or acrobatics (such as dancing in music videos, pole dancing or aerial acrobatics).
  • An image of a painting, sculpture, photograph or other artwork containing nudity.

Content associated with common or known fetishes, but that is not graphic or overtly sexual in nature

  • Videos or images of feet with no additional context to suggest a sexual purpose.
  • Depictions of individuals in commonly sexualised fancy dress (such as fur suits, nurses, maids, butlers, police officers).

Marketing material and depictions used for the promotion and sale of sex toys and sexual wellness products

  • Depictions that focus on a sex toy or sexual wellness product ‘as is’ rather than ‘in use’, and that do not show full frontal nudity or genitalia.
  • Descriptions of the efficacy and features of sex toys or sexual wellness products, that are designed for the promotion, sale and/or consumption of the product, rather than sexual arousal

Further detail and examples on what Ofcom considers to be pornographic content can be found in Section 2 of our Guidance on Content Harmful to Children (PDF, 806 KB)

Check if the Online Safety Act applies to your service

Find out which service type you provide and if the rules are likely to apply to your service.

The rules will apply to your service if it:

  • has a significant number of UK users; or
  • has UK users as one of its (or sole) target markets; or
  • is capable of being used by UK users, and there are reasonable grounds to believe there is a material risk of significant harm to UK users

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Types of services in scope of the Act

The duties that apply to you will depend on whether you provide a Part 3 or Part 5 service.

Part 3 services – user-to-user or search services

A Part 3 service is a service that has user-to-user or search functionalities. This includes services such as cam, fan and tube sites.

User-to-user services are online services that enable users to generate, share or upload content (such as messages, images, videos, comments, audio) on the service that may be encountered by other users of the service. This includes services that enable user interactions. These services are regulated under Part 3 of the Act.

Search services are internet services which are, or include, a search engine. A search engine is a service or functionality that enables users to search more than one website and/or database or, in principle, to search all websites and/or databases.

Part 5 services – publishers of pornography

A Part 5 service is an internet service on which pornographic content is published or displayed by the provider of the service. This is defined in the Act as ‘regulated provider pornographic content’. This is distinct from Part 3 services which host user generated content that may include pornography.

Duties for Part 3 services

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1

All Part 3 services must complete a children’s access assessment to determine whether they are likely to be accessed by children. To compete a children’s access assessment, visit children's access assessment duties under the Online Safety Act.

If you have age assurance in place on your service that meets the criteria for being highly effective, and you have access controls in place, you can conclude that it is not possible for children to access your service. If this is the case, you do not then need to move to stage 2 of the children’s access assessment or carry out a children’s risk assessment.

2

If, after completing the children’s access assessment, you determine that the service, or part of your service, is likely to be accessed by children then you need to complete a children’s risk assessment for the parts which are still accessible.

The purpose of the children’s risk assessment is to improve your understanding of the risk of harm to children on your service. 

It will help you understand:

  • how children could encounter harmful content
  • how your service’s user base
  • features and other characteristics could increase the risk of this
  • what safety measures you need to put in place to protect children

For guidance about carrying out an children’s risk assessment, visit protection of children duties under the Online Safety Act.

3

After you've completed a children’s risk assessment, you will have an understanding of measures you will need to put in place to protect children based on your specific service.

All services that allow pornography will need to implement highly effective age assurance measures to ensure that children are not normally able to encounter pornographic content.

To ensure that an age assurance process is, in practice, highly effective at correctly determining whether or not a user is a child, your age assurance process should fulfil each of the following four criteria:

  • it is technically accurate;
  • it is robust;
  • it is reliable; and
  • it is fair

You should also consider interoperability and accessibility when deploying an age assurance process.

We have also provided a non-exhaustive list of age assurance methods that are capable of being highly effective, some that can be done in-house or by purchasing a method from a third party. These can include:

  • credit card checks
  • facial age estimation
  • open-banking
  • photo-ID matching
  • mobile-network operator age checks
  • digital identity services
  • email-based age estimation

Our guidance is clear that some methods are not capable of being highly effective, including self-declaration of age, and age verification through online payment methods which do not require the user to be 18 or over.

Any age assurance process will also need to comply with the UK Data Protection Act and you can find more information about that on the Information Comissioner's Office website.

For further guidance about implementing highly effective age assurance, visit age assurance duties under the Online Safety Act.

4

The purpose of conducting an illegal content risk assessment is to ensure you understand the risks to your users encountering illegal content on your service, and if you have a user-to-user service, the risk that the service may be used to commit or facilitate certain priority offences.

It will help you understand:

  • how harm could take place on your service
  • how your service's user base, features and other characteristics could increase the risks of harm
  • what safety measures we recommend you put in place to protect people, especially children

The harms most relevant to pornography services are outlined in our Register of Risks and Illegal Content Judgements Guidance. The harms we believe are most relevant to adult service providers are:

For guidance about carrying out an illegal content risk assessment, visit illegal content duties under the Online Safety Act.

Duties for Part 5 services

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1

You must put highly effective age assurance in place on your service to prevent under-18s from accessing pornographic content on your service.

For guidance about implementing highly effective age assurance on your service, visit age assurance duties under the Online Safety Act.

2

You must also keep a record of:

  • the kinds of age assurance you have used and how you have used them on your service.
  • how you have had regard to privacy and data protection laws when deciding which age assurance process to use and how

For more information about the age assurance record-keeping duties, you can read the Part 5 guidance.

Enforcement updates

Read the latest updates to our enforcement programme to protect children.

Stay in touch and up to date

Sign up to Ofcom’s Online Safety Briefing newsletter and you’ll be the first to know when we publish updates on our online safety work.

Want to know more? You can get in touch with the Porn Supervision team via email. We may not respond to every query but may update our website with more advice.

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